NOPTAprogram
Annual compliance program
1. Purpose
The purpose of this document is to provide an
overview of the nature and scope of the National
Offshore Petroleum Titles Administrator’s (NOPTA)
external annual compliance activities.
1.1 Relevant legislation


Offshore Petroleum and Greenhouse Gas
Storage Act 2006 (OPGGSA)
Offshore Petroleum Greenhouse Gas Storage
(Resources Management and Administration)
Regulations 2011 (RMA Regulations)
2. Annual compliance program
A key component of NOPTA’s compliance and
enforcement strategy is the annual compliance
program which monitors and assists titleholders to
comply with the legislative requirements. The
program uses the graduated, risk based approach
as provided for by the NOPTA ‘Compliance and
enforcement policy’.
The NOPTA annual compliance program includes
two main aspects; proactive and reactive
compliance activities.
2.1 Proactive compliance activities
MELBOURNE
Level 1
451 Lt Bourke St
Melbourne VIC 3000
GPO Box 4634
Melbourne VIC 3001
T: 03 8199 0300
Identify compliance/
regulatory issues
Evaluation
Implementation
(Annual Compliance
Program - proactive)
Consultation/
Communication
Analyse
NOPTA’s proactive compliance activities involve
activities such as reviewing titleholder’s progress
and records against the legislative requirements
and approved title conditions. For example reviews
of (not exclusive):





conditions of title (including work programs)
field development plans
rates of recovery
statutory directions, and/or
submission of data.
A continuing focus of NOPTA is to conduct reviews
on the information provided by titleholders as part
of their data submission requirements. This
includes making sure titleholders comply with the
submission timeframes and information
requirements specified in the legislation. The
majority of reviews consider reports which are
received by NOPTA and if further information is
needed this is discussed with the titleholder.
In conjunction with conducting compliance checks
on data and reports submitted under the legislation
this process also assists NOPTA to identify
additional target areas for inspection. The
identification of target areas evolves as NOPTA
gathers information about compliance issues and
risk areas.
The cycle of NOPTA’s proactive compliance
activities is depicted below.
PERTH
Alluvion Building
Level 8
58 Mounts Bay Rd
Perth WA 6000
GPO Box 7871
Perth WA 6850
T: 08 6424 5300
NOPTA conducts themed compliance activities i.e.
targeting a specific title type, compliance issue or
subject matter. Where it is identified that these
activities may impact titleholders the target area
will be communicated to titleholders. NOPTA will
select titles, taking into account the titleholders
(size, experience, compliance history and stance),
age and maturity of titles and the need to review
titles across different offshore areas.
2.2 Reactive compliance activities
In some circumstances NOPTA is required to
conduct investigations. Investigations are reactive,
resulting from identified instances or allegations of
non-compliance. These may arise from scheduled
compliance activities, or other means such as
information provided by internal or external
stakeholders. All reactive compliance activities are
conducted in accordance with the NOPTA
Compliance and Enforcement Policy.
www.nopta.gov.au
NOPTAprogram
3. NOPTA compliance and
enforcement policy
Compliance and enforcement activities undertaken
as part of NOPTA’s Annual Compliance Program
will be consistent with NOPTA’s Compliance and
Enforcement Policy. This policy is published on
NOPTA’s website.
4. Statutory powers of the Titles
Administrator and Inspectors
During any proactive compliance activity or
investigation, NOPTA will communicate with the
titleholder to make sure they understand how the
activity or investigation is progressing. In order to
do this, in its initial communication, NOPTA will ask
the titleholder to nominate a contact point for all
requests from NOPTA. NOPTA will also nominate
a case officer who the titleholder can direct their
queries to.
5.1 Outcomes
While the annual compliance program focuses on
NOPTA’s policy to encourage voluntary
compliance and to help titleholders to comply, the
Titles Administrator may use its statutory powers to
request information from titleholders. For example,
those available under Part 7.1, Division 3 of the
OPGGSA, specifically section 699, to request
information and documents from titleholders.
Also, in certain circumstances, NOPTA may utilise
inspectors appointed under the OPGGSA to assist
with activities under the compliance program.
5. Communications with titleholders
NOPTA publishes documentation on its website,
and undertakes industry consultation, to make sure
that titleholders are aware of their obligations
under the legislation. This communication is aimed
at educating titleholders with regard to the Joint
Authority’s and NOPTA’s expectations.
Once the process has been finalised, the
titleholder will be notified, in writing, of the
outcome. This notification will provide details of
what was found and highlight any issues
addressed. If any enforcement action is needed,
this will be addressed in accordance with the
NOPTA Compliance and Enforcement Policy.
6. Timeframe
The timeframe of each type of compliance activity,
proactive and reactive, varies case by case as it is
dependent on the subject being reviewed/
investigated.
7. Further information
For further information please contact:
Name
Rachel Fry
Nicole Filbay
Email
rachel.fry@nopta.gov.au
nicole.filbay@nopta.gov.au
Document Control
PERTH
Alluvion Building
Level 8
58 Mounts Bay Rd
Perth WA 6000
GPO Box 7871
Perth WA 6850
T: 08 6424 5300
MELBOURNE
Level 1
451 Lt Bourke St
Melbourne VIC 3000
GPO Box 4634
Melbourne VIC 3001
T: 03 8199 0300
Document Title
Approval Date
Approver
Next Review Date
Reviewed By
Annual Compliance
Program
15 January 2013
Titles Administrator
April 2015
Compliance and
Operations Support
Annual Compliance
Program
28 April 2015
Titles Administrator
April 2016
Compliance and
Operations Support
www.nopta.gov.au